The Simpleum Media GmbH – the provider of these pages and developers of the app SimpleumSafe and SimpleumCheck – take the protection of your personal data very seriously.
Simpleum Media GmbH, Hamburg, Germany – (also “Simpleum”, “we”, “our”, “us”) operates the website simpleum.com (also “website”) and the Applications SimpleumSafe and SimpleumCheck (also “app”).
With regard to the terminology used, such as “processing” or “responsible person”, we refer to the definitions in article 4 of the General Data Protection Regulation (GDPR).
The responsible organization in the sense of the data protection laws is:
Simpleum Media GmbH
Types of data processed:
– Inventory data (e.g. names, addresses).
– Contact information (e.g. e-mail, telephone numbers).
– Content data (e.g. text input, photographs, videos).
– usage data (e.g. websites visited, interest in content, access times).
– Meta-/communication data (e.g. device information, IP addresses).
Categories of persons affected
Visitors, users of the online offer, customers and testers of our apps (in the following we refer to the persons concerned in summary as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact inquiries and communicating with users.
– Security measures.
– Range Measurement/Marketing
– Purchase of our apps
– Crash Analysis of our apps
– Metric analysis of our apps
“Personal data” shall be any information relating to an identified or identifiable natural person (Hereinafter “the person concerned”) a natural person is considered to be identifiable, either directly or indirectly, in particular by assigning to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special characteristics can be identified, are the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” means any operation performed with or without the help of automated procedures or any such series of operations in connection with personal data. The term extends far and covers virtually every use of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific person concerned without the addition of additional information, provided that such additional Information shall be kept separately and subject to technical and organizational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data, which consists in the use of such personal data to assess certain personal aspects relating to a natural person, in particular aspects to analyze or predict the performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or location change of this natural person.
The “person responsible” shall mean the natural or legal entity, authority, institution which, alone or jointly with others, decides on the purposes and means of processing personal data.
“Processor” means a natural or legal person, authority, institution that processes personal data on behalf of the responsible party.
Relevant legal bases
In accordance with article 13 of the GDPR, we will inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following shall apply: The legal basis for obtaining consent is Article 6 para. 1 lit. a and article 7 GDPR, the legal basis for processing in order to fulfil our services and to carry out contractual measures and to answer inquiries is Article 6 para. 1 lit. b GDPR, the legal basis for processing in order to comply with our legal obligations is article 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Article 6 para. 1 lit. f GDPR. In the event that vital interests of the person concerned or of another natural person require the processing of personal data, article 6 para. 1 lit. d GDPR shall be used as a legal basis.
We shall, in accordance with para. 32 GDPR, take into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of processing, as well as the varying likelihood of occurrence and severity of the risk for the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, availability and separation. In addition, we have established procedures that guarantee the perception of the rights concerned, the deletion of data and the reaction to the data being compromised. We also take into account the protection of personal data in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technical design and data protection-friendly preferences (para. 25 GDPR).
Cooperation with processors and third parties
If we disclose data to other persons and companies (processors or third parties) as part of our processing, transmit them to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (for example, if a transfer of the data to third parties, as to payment service providers, according to article 6 para. 1 lit. b GDPR is required for the performance of the contract), you have agreed to a legal obligation to do so or on the basis of our legitimate interests (e.g. in the case of the use of agents, web hosts, etc.).
If we entrust third parties with the processing of data on the basis of a so-called “data processing agreement”, this is done on the basis of article 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third party services or disclosure, or transmission of data to third parties, this only occurs when it is done to fulfil our (pre) contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests.
Subject to legal or contractual permits, we process or leave the data in a third country only in the presence of the special conditions of art. 44 ff. GDPR. i.e. processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy shield”) or observance of officially recognized special contractual Obligations (so-called “standard contractual clauses”).
Rights of the persons concerned
You have the right to request confirmation as to whether such data will be processed and for information on this data as well as for further details and copy of the data in accordance with article 15 GDPR.
According to article 16 GDPR, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data to be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you which you have provided to us be obtained in accordance with article 20 GDPR and to request their transmission to other persons responsible.
You have also the right, pursuant to article 77 DSGVO, to submit a complaint to the competent supervisory authority.
You have the right to revoke your consent pursuant to article 7 para 3 GDPR with effect for the future.
You may withdrawal at any time object to the future processing of the data relating to you in accordance with article 21 GDPR. The opposition may in particular be against processing for direct marketing purposes.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with articles 17 and 18 GDPR. Unless expressly stated in the scope of this data protection declaration, the data stored with us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with statutory retention obligations. If the data is not deleted because it is necessary for other and legally permissible purposes, its processing will be restricted. i.e. the data is locked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage shall be carried out in particular for 10 years pursuant to § § 147 para. 1 AO, 257 para. 1 No. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, taxation of relevant documents, etc.) and 6 years Pursuant to § 257 para 1 No. 2 and 3, para 4 HGB (commercial letters).
According to legal requirements in Austria, the storage is carried out in particular for 7 years pursuant to § 132 para. 1 BAO (Accounting documents, documents/invoices, accounts, documents, business documents, statement of revenue and expenses, etc.), for 22 years in connection with Land and for 10 years for documents relating to electronically supplied services, telecommunications, radio and television services provided to non-entrepreneurs in EU member States and for which the Mini-one-Stop-Shop (MOSS) is taken.
Data Processing Agreements
We have concluded contracts for data processing with all subcontractors and fully implement the strict specifications of the German privacy authorities in the use of external services.
The use of our website is usually possible without providing personal data. As far as personal data (e.g. name, address or e-mail addresses) are collected on our website, this is always carried out on a voluntary basis as far as possible. This data will not be passed on to third parties without your express consent.
We would like to point out that data transmission on the Internet (e.g. when communicating via e-mail) can have security gaps. It is not possible to completely protect the data from access by third parties.
Web- and E-Mail-Server location
The Web servers and the e-mail servers for the operation of simpleum.com are operated by Strato AG, Berlin, Germany on behalf of the Simpleum Media GmbH. The server location is Germany.
Encrypted transmission in the browser
This site uses SSL or TLS encryption for security reasons and to protect the transmission of any content that you send to us as a page operator. An encrypted connection is recognized by the fact that the browser’s address bar changes from “http://” to “https://” and to the lock icon in your browser line.
If SSL or TLS encryption is enabled, the data that you transmit to us cannot be read by third parties.
Cookies and right of objection in direct marketing
“Cookies” are small files that are stored on users’ computers. Within the cookies, different data can be stored. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. As temporary cookies, or “session cookies” or “transient cookies”, cookies are called, which are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart can be stored in an online shop or a login status. “Permanent” or “persistent” are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the users visit them after several days. Similarly, in such a cookie, the interests of users who are used for range measurement or marketing purposes can be stored. “Third-party-cookie” means cookies that are offered by other providers than the person in charge of the online offer (otherwise, if it is only their cookies, it is called “first-party Cookies”).
If users do not want cookies to be stored on their computer, they will be asked to disable the corresponding option in their browser’s system preferences. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Furthermore, the storage of cookies can be achieved by means of their shutdown in the settings of the browser. Please note that you may not be able to use all the functions of this online offer.
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services that we use for the purpose of operating this online offer.
We, or our hosting provider process, inventory data, contact data, content data, contract data, usage data, meta-and communication data of customers, interested parties and visitors of this online offer based on our legitimate interests in an efficient and secure provision of this online offer according to article 6 para 1 lit. f GDPR in conjunction with article 28 GDPR (Final Order Processing contract).
Collection of access data and logfiles
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of article 6 para 1 lit. f. GDPR data about each access to the server on which this service resides (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, transferred data quantity, message about successful retrieval, browser type and version, the operating system of the user, referrer URL (the previously visited page), IP address and the requesting providers.
Logfile information is stored for a maximum of 7 days for security reasons (e.g. for the investigation of abuse or fraud actions) and then deleted. Data for which further storage is required for evidence is excluded from the deletion until the final clarification of the respective incident.
Use of Cloudflare – Web firewall and Content Delivery Network (CDN)
To secure this web site with a web firewall and optimize loading times, Cloudflare is used as a CDN (“Content Delivery Network”). Cloudflare collects on the basis of our legitimate interests within the meaning of article 6 para. 1 lit. f. GDPR data about each access to the server, as all requests are routed through their firewall and proxy servers.
This data is consolidated into non-deactivatable statistics. The collected raw data will be deleted there according to your own data usually within 4 hours, at the latest after 3 days. Cloudflare stores many web pages temporary and the user gets these websites generally delivered by the nearest geographically located data center. Cloudflare operates various data centers in Europe.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information of the user for the processing of the contact request and its processing is according to article 6 para 1 lit. b GDPR processed. Users’ information can be stored in a customer relationship management system (“CRM system”) or similar request system.
We will delete the requests if they are no longer required. We review the requirement every two years; The statutory archiving obligations also apply.
We use the “Support Service” of Freshdesk.com (from Freshworks Inc.). The data you enter will be stored there. By submitting a contact or support request, you agree to the terms and conditions of Freshworks Inc. for the storage and processing of the data.
We use the helpdesk system “Freshdesk”, of the provider Freshworks, Inc., 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066, USA, in order to be able to process requests of the users faster and more efficiently (legitimate interest according to article 6 para 1 lit. f. GDPR).
Freshdesk is certified under the Privacy Shield Agreement and provides an additional guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnbQAAS&status=Active ).
Freshdesk uses the data of the users only for the technical processing of the inquiries and does not pass them on to third parties. To use Freshdesk, it is necessary to specify a correct e-mail address at least. Use of pseudonyms is possible. In the course of processing service requests, it may be necessary to collect further data (name, address). The use of Freshdesk is optional and serves to improve and accelerate our customer and user service.
If users do not agree with data collection and data storage in the external system of Freshdesk, we offer alternative contact options for the submission of service requests by e-mail (firstname.lastname@example.org).
Integration of third party services and content
It is possible that content or services of third parties, such as fonts from other websites, can be included within our online offer. The inclusion of third-party content always requires third-party providers to perceive the IP address of the users, since they would not be able to send the content to the user’s browser without the IP address.
The IP address is therefore required to display this content. Third-party content providers may also set their own cookies and process the user’s data for their own purposes. They can create user profiles from the processed data. We will use this content sparingly and data-avoidable and choose reliable third-party providers in terms of data security.
The following presentation provides an overview of third-party providers as well as their contents, along with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, opposition possibilities (so-called opt-out):
https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
Data will not be transferred to YouTube until you play a video.
We maintain online presences within social networks and platforms in order to communicate with the active customers, interested parties and users and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
With the following instructions we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure as well as your right to object. By subscribing to our newsletter, you agree to the reception and the procedures described.
Content of the newsletter: We send out newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. If the contents are specifically described in the context of an application for the newsletter, they are decisive for the consent of the users. In addition, our newsletter contains information about our services and us.
Double opt-In and logging: the registration for our newsletter is done in a so-called double-opt-in procedure. i.e. After you have registered, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the logon and confirmation date as well as the IP address. The changes to the data stored by the shipping service provider are also logged.
Registration information: To sign up for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to provide a name for your personal address in the newsletter.
The sending of the newsletter and the success measurement associated with it are carried out on the basis of the consent of the recipients according to article 6 para 1 lit. a, art. 7 GDPR i. V. m § 7 para 2 No. 3 UWG or on the basis of the legal permission according to § 7 para. 3 UWG.
The logging of the registration procedure is based on our legitimate interests in accordance with article 6 para 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newsletter-module that serves our business interests as well as the expectations of the users and allows us to provide proof of consent.
Cancellation – You can cancel the reception of our newsletter at any time, i.e. revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may store the e-mail addresses held for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possible defence against claims. An individual cancellation request is possible at any time, if at the same time the former existence of a consent is confirmed.
Participation in affiliate partner programs
Within our online offer we rely on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) according to article 6 para 1 lit. f GDPR industry-standard tracking measures to the extent necessary for the operation of the Affiliatesystems. In the following we clarify the user’s technical background.
The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if e.g. links or services of third parties are offered after a contract conclusion). The operators of the respective websites receive a commission when users follow the Affiliate links and then take the offers.
In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available to us, the offers are then on the instigation of the Affiliate links or our online platform. For this purpose, the Affiliate links and our offers are supplemented by certain values, which can be set as a part of the link or otherwise, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, an online identification of the user, as well as Tracking-specific values, such as advertising agent ID, partner ID, and categorizations.
Order Processing in the online shop
We process the data of our customers in the context of the ordering processes in our online shop, in order to enable you to select and order the selected products and services, as well as their payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing belong to our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services within the framework of the operation of an online shop, billing, delivery and customer services. We use session cookies to store the contents of the basket and permanent cookies for the storage of the login status.
The processing takes place on the basis of article 6 para 1 lit. b (Execution of order transactions) and (c) (statutory archiving required) GDPR. The information required for the reasons and performance of the contract must be indicated. We disclose the data to third parties only in the context of delivery, payment or within the framework of legal permits and obligations to legal advisers and authorities. The data will only be processed in third countries if this is necessary for the performance of the contract (e.g. on customer request upon delivery or payment).
The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).
Order processing is carried out by Bright Market, LLC d/b/A FastSpring, 801 Garden Street, Santa Barbara, CA 93101, USA.
FastSpring is certified under the Privacy Shield Agreement and provides an additional guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000PC9JAAW&status=Active).
Google Tag manager with anonymized IPs
Google Tag Manager is a solution that allows us to manage so-called website tags over a user interface (including Google Analytics and other Google marketing services in our online offering). The tag manager itself (which implements the tags) does not process the user’s personal data. With regard to the processing of the user’s personal data, the following information about the Google services is referred to. Usage Guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google Analytics with anonymized IPs
Google is certified under the Privacy Shield Agreement and provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by the users, to compile reports on the activities within this online offer and for further, with the use of this online offer and the services connected to the Internet to provide us with. In this process, pseudonyms of user profiles can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the users is reduced by Google within Member States of the European Union or in other contracting States of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the United States and shortened there.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by a corresponding setting of their browser software; Users may also prevent Google from collecting the data generated by the cookie and related to their use of the online offer, as well as the processing of such data by using the browser plug-in available at the following link Download and install: http://tools.google.com/dlpage/gaoptout?hl=de.
The user’s personal data will be deleted or anonymized after 14 months.
Google AdWords and conversion measurement with anonymized IPs
We use the online advertising program “Google AdWords” on our website and in this context conversion tracking (visit action evaluation). Google conversion tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
Google is certified under the Privacy Shield Agreement and provides a guarantee to comply with European Data protection Law ( https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
When you click on a Google-switched ad, a conversion tracking cookie is placed on your computer. These cookies have a limited validity, do not contain personal data and therefore do not serve for personal identification. If you visit certain pages of our website and the cookie has not expired, Google and we can see that you clicked on the ad and were redirected to that page. Each Google AdWords customer receives a different cookie. Thus, there is no way that cookies can be tracked through the websites of AdWords customers.
The information obtained using the conversion cookie is intended to create conversion statistics. We’ll see the total number of users who clicked on one of our ads and were redirected to a conversion tracking tag page. However, we do not receive any information that allows users to identify themselves personally. The processing is carried out on the basis of article 6 (1) lit. f GDPR from the legitimate interest in targeted advertising and the analysis of the impact and efficiency of this advertising.
You can disable Google AdWords on our website. See Google tag Manager.
||Active language on the website
||Cloudflare WebFirewall Identifikation (more information)
||Google Analytics: Unique but random number to be able to recognize a user on this site. Pseudomized.
||Google Analytics: For web pages with very high call numbers, the number of messages is throttled to Google
Crash and Error analysis
The collected diagnostic data is processed in the United States and is used by Simpleum to optimize or quickly detect simple to critical bugs in the app. It is not possible to draw conclusions about the identity of the user and the type and contents of the files in the Safe.
You can choose to send or no longer send usage information and diagnostic data by adjusting the settings in the app. In the app’s delivery state, this option is enabled.
Capturing usage metrics
With usage metrics, we mean counting how often certain functions are called in the app. For example, how often a new Safe is created or how often the help is called.
We use Fabric and the Answers analytics plugin from Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, based on our legitimate interests (i.e. maintaining and improving the quality of the software, ensuring the promised services in meaning of article 6 para. 1 lit. f GDPR).
It is not possible to draw conclusions about the identity of the user and the type and contents of the files in the safe. In addition to the information automatically provided by Fabric and Answers, simplistic uses custom events (see below) to collect and evaluate data on specific actions performed by the user. This data helps to understand, for example, which functions are often or rarely used. Details regarding the user’s data handling by Google as well as his rights and settings for the protection of his personal data, the user can read the privacy information of Fabric here: https://fabric.io/terms und abric Data Processing and Security Terms
The following custom events include the number of uses of features in the app (no content data is recorded): manual backup, restore, create recovery password, recover password, open safe (incl. number False logins before successful login), call the simpleum.com (home page, FAQ, help, bug report, request for new function), rate app, recommend by email, recommend via imessage.
A custom event is created for checking the safe integrity. It records the number and type of errors found, but does not record information about the files in the safe. (Example: CountNonTrashedChilds – a folder in the trash contains files that are not in the trash)
A custom event is recorded when using the safe information on the number of files and folders as well as the size of the entire safe is abstracted. This is done in an abstract way, so that no inference can be made to the user. The number or size is summarized in grouped sizes (1, 2, 5, 10, 20,…, 10,000, 20,000,…).
You can choose to send or no longer send usage information and diagnostic data by adjusting the settings in the app. In the app’s delivery state, this option is enabled.
SimpleumCheck checks automatically at startup whether a new program version is available on simpleum.com and informs the user. This function can be turned off.
If the “Learn more” button is pressed for a check entry, a corresponding website is called up on simpleum.com.
Otherwise, SimpleumCheck does not transfer data to or via the Internet.
Any dispute or claim arising out of this privavy policy shall be finally settled by arbitration in Hamburg, Germany.
Updated: 24.05.2018, 11:00
Zu Teilen erstellt mit Datenschutz-Generator.de von RA Dr. Thomas Schwenke (mit einigen Anpassungen)